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Do You Need a Hero? Emergency Action Plans

Posted on December 8th, 2016 by in Chemical Manufacturing Excellence


“We all need our heroes, not just in time of chaos but also in the time of peace.”  Paul Bamikole

Being a firefighter is about as safe as any typical job in the United States.  Fighting industrial fires, on the other hand, is about as dangerous as the most dangerous jobs that are legal.

The Dangers of Firefighting

According to the Bureau of Labor Statistics (BLS), the fatality rate for loggers in 2014, the most recent year for which there is data, is 111 fatalities per full-time equivalent.  For roofers, it is 47.  But according to a recent report by the National Fire Protection Association (NFPA), the fatality rate is 5.0 fatalities per 100,000 firefighters.  That’s not much higher than the overall fatality rate reported by the BLS for the work force at large:  3.4 fatalities per 100,000 full-time equivalent workers (FTEs).

Organizations principally concerned with fire prevention look at fatality rates differently.  Instead of fatalities per 100,000 FTEs, they look at fatalities per 100,000 fires.  The more fires to which a firefighter responds, the more likely he or she is to be killed on the job.  The United States Fire Administration, an agency of FEMA, has been tracking firefighter fatalities for decades.  While the rate varies from year to year, it has averaged 3.3 fatalities per 100,000 fires over the last fifteen years with no clear trend up or down.

Residential structure fires account for greatest number of firefighter deaths (64%) because of the shear number of residential fires, but at a rate of 2.7 fatalities per 100,000 residential fires, residential fires are among the safest to which firefighters respond.  Industrial fires, on the other hand, are the most dangerous fires to which a firefighter can respond.  Industrial fires account for 5% of firefighter deaths but at a fatality rate of 31 fatalities per 100,000 industrial fires.  Fighting residential fires is not much more dangerous than the average job in the United States; fighting industrial fires is comparable to the most perilous jobs we have.

Recent Firefighter Fatalities at Chemical Plants

Two recent disasters in the chemical process industry have resulted in the deaths of firefighters.  One disaster was the acrylic acid tank explosion at the Nippon Shokubai plant in Himeji, Japan on September 29, 2016.  One person was killed, a firefighter.  Another disaster was the pipeline explosion within the BASF facility at Ludwigshafen, Germany on October 17, 2016, less than three weeks later.  Four were killed. One was a sailor on a nearby tanker ship, and three were firefighters from the company fire brigade.  None were operators or mechanics.

For students of process safety, BASF’s plant in Ludwigshafen will be familiar, as it is the site of the first process disaster many of us study—the 1921 ammonium nitrate explosion that killed over 500 and finally convinced our industry that ammonium nitrate was dangerous.  I’m sorry to see Ludwigshafen on the list of newsworthy process disasters once again.

Other Recent Chemical Disasters

A little over a year ago, a fire and explosions at the Ruihai Logistics warehouse in Tianjin, China killed 173.  Over half of them were firefighters.  On August 12, 2015, 88 firefighters died responding to a fire at the warehouse, which contained miscellaneous chemicals, including flammables, corrosives, toxics, and oxidizers.  In this case, there is widespread agreement that the firefighters had no idea of what they were up against.

west fertilizer

West Fertilizer Company fire and explosion Photo credit: U.S. Chemical Safety Board

In the United States, the fire and explosion of ammonium nitrate at the West Fertilizer Company facility in West, Texas is still being studied.  On April 17, 2013, fifteen were killed when the warehouse exploded.  Twelve of the dead were firefighters and other first responders.

No Heroes

OSHA’s regulations for emergency response, 29 CFR 1910.38 and 29 CFR 1910.120, require extensive planning and training.  In regard to 29 CFR 1910.120, commonly known as “HazWOpER,” employers are exempted from developing emergency response plans for hazardous releases if they will “evacuate their employees from the danger area when an emergency occurs,” and “not permit any of their employees to assist in handling the emergency, so long as they provide an emergency action plan in accordance with 29 CFR 1910.38”.  In turn, 29 CFR 1910.38 requires that an emergency action plan have procedures for reporting a fire or other emergency and plans for evacuation and rescue duties.  The emphasis that both of these regulations place on evacuation has lead many organizations to develop “No Heroes” policies.

Almost a year after the West Fertilizer disaster, the Dallas Morning News interviewed a surviving firefighter who insisted that once at the fire, every instinct would be to fight it—to put water on it.  “You couldn’t have dragged me out of there.”

We are in the habit of calling firefighters who die while fighting a fire “heroes.”  Not so much so for the firefighters that live to fight another fire.  To the extent that these men and women were there to save the lives others, they are heroes, both the living and the dead.  But to the extent they were simply there to save assets and to protect property, then sadly, they were just victims.  Lionizing fallen firefighters encourages a kind of “heroism” that gets emergency responders killed.

No Victims

It is important to understand what we expect in an emergency.  To keep operating?  Evacuation?  Firefighting?  A common scenario in PHAs is the case of the blocked-in pressure vessel during an external fire, which then overpressures and explodes.  When evaluating the consequences of such a scenario, PHA teams usually conclude that fatalities are unlikely.  The teams recognize that during an external fire large enough to cause overpressure, personnel do not break out the sticks and marshmallows; they evacuate.

When asked whether firefighters will be in the area responding to the fire, though, PHA teams typically hesitate.  They don’t know what firefighters will do.  Often, they don’t know what firefighters should do.  They all agree, however, that there is nothing in that vessel that is worth dying for.  Whether operating and maintenance personnel or first responders, PHA teams do not want to see victims.  As long as firefighters respond to chemical disasters, however, we should continue to expect victims.

emergency drill

Emergency drill at Brussels Airport Photo credit: Brussels Airport

Plan for Disaster

The worst time to plan for an emergency is during the emergency.  When firefighters show up at a fire, their plan is to “put water on it.”  Unless other plans are already in place, the default plan is to fight the fire.

Increasingly, we are recognizing that once everyone is safely out, including firefighters themselves, there is no property worth dying for.  We know that what we need from firefighters is the rescue of personnel.  In our heart of hearts, though, we are still looking for heroes.

Preparing an emergency action plan is not just an exercise to satisfy a regulatory requirement.  It is a mechanism for anticipating what can go wrong and preparing for it.  It is not enough for a facility to have an emergency action plan; the facility must share it with everyone that has a role to play in that emergency.  Within the facility, this can be a challenge, but a challenge that can be overcome with determination and leadership from senior management.

Outside of the facility, sharing the plan is more than a challenge.  It can sometimes seem an insurmountable problem.  While motivational speakers are fond of saying that “there are no problems, only opportunities,” some opportunities are much more intractable than others.  Convincing a local fire department that is struggling with limited resources that it wants to meet with us to plan for emergencies can be a major hurdle, especially when we are also struggling with limited resources.  However, overcoming the obstacle is something we must do, and it is on us to make it happen.

Share Our Plans

When a disaster happens and firefighters die, it is not the fire department that makes the headlines.  It’s the facility.  Make sure we’ve planned for each emergency, that we know what to expect, and that the first responders upon whom we rely know what to expect.  Share our plans and make sure everyone gets it.  Facilities can be built again, but a fallen firefighter is fallen forever.


All opinions shared in this post are the author’s own.

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